At least five other children were returned to their parents almost immediately after being removed by concerned gardai in the past year, the Irish Independent has learned.
The cases all pre-date the current controversy involving children in Roma families.
False alarms are relatively common, according to child welfare workers, although no official statistics exist.
"Gardai sometimes make split-second decisions to remove a child from their home, honestly believing that child is at risk," said one HSE source.
"But there have been a number of cases where, on further investigation, it turned out those fears were unfounded and the child was returned to its parents."
Under the 1991 Child Care Act gardai can remove a child from their home where they have "reasonable grounds" for believing there is an immediate risk to the health and welfare of the child.
In doing so, gardai must believe the risk is so immediate that they cannot wait for the courts to decide on an emergency care order.
Gardai must place the child into the care of the HSE as soon as possible.
The HSE must then make an emergency care order application at the district court.
The HSE has the power to retain custody of the child until such time as the court makes a decision on the order.
Gareth Noble, a solicitor specialising in juvenile justice issues, said in the past year he had encountered five cases where children were returned to their parents soon after gardai had taken them into HSE care.
These included cases where parents didn't turn up when their child was appearing at a juvenile court.
Mr Noble said he had sympathy for the gardai in these cases.
"It is really difficult for the gardai as it's a case of being damned if they do and damned if they don't," he said.
He described the legislation as "very subjective" and the threshold for "reasonable grounds" as very low.
However, he said the system had checks and balances and required the involvement of the HSE and the courts before a care order was issued.
"I am comforted by the fact that in this type of case, although it is time limited, there is a triple-lock mechanism in that it requires the gardai, the HSE and the court all to act," he said.